San Diego Environmental Health Corrective Action Programs Overview
In the County of San Diego, the Department of Environmental Health oversees Corrective Action programs for permitted facilities. This includes the Corrective Action Designation, SAM Programs, exclusions from Corrective Action, and sources of Corrective Action cases. The program covers releases from permitted sources, small spills exempted from CA, and actions required in various scenarios like inspections, assessments, and suspected releases.
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Corrective Action Program Ewan Moffat County of San Diego Department of Environmental Health Site Assessment & Mitigation Program
Corrective Action Designation O On February 28, 2014, the Department of Toxic On February 28, 2014, the Department of Toxic Substances Control (DTSC) delegated authority to Substances Control (DTSC) delegated authority to DEH DEH, as the local Certified Unified Program Agency , as the local Certified Unified Program Agency (CUPA), to (CUPA), to oversee Corrective Action at permitted oversee Corrective Action at permitted facilities in the County of San Diego. facilities in the County of San Diego. O Applies to releases of substances from CUPA Applies to releases of substances from CUPA permitted facilities. permitted facilities.
SAM Programs O Local Oversight Program (LOP) Local Oversight Program (LOP) O Voluntary Assistance Program (VAP) Voluntary Assistance Program (VAP) O Corrective Action Program (CAP) Corrective Action Program (CAP)
Corrective Action (CA) Corrective Action does not apply Corrective Action does not apply to: to: O R Releases from non eleases from non- -CUPA permitted sources CUPA permitted sources O Small spills and releases that are cleaned up as part of Small spills and releases that are cleaned up as part of routine housekeeping. routine housekeeping.
Sources of Corrective Action Cases O Analytical data submitted in compliance with Analytical data submitted in compliance with Monitoring Well Program permits at sites that Monitoring Well Program permits at sites that are or were CUPA permitted were CUPA permitted facilities facilities are or O Referrals from Hazardous Materials Division, Referrals from Hazardous Materials Division, including routine inspections and PBR/CA closures including routine inspections and PBR/CA closures O Recalcitrant Voluntary Assistance Program cases that Recalcitrant Voluntary Assistance Program cases that are or were CUPA permitted facilities are or were CUPA permitted facilities
When is Corrective Action Required? Inspections Phase II Environmental Assessment PBR/CA Closure Suspected Release No Further Clean Closure Investigation Required Further Investigation Required Corrective Action Required Corrective Action Required
Corrective Action Process O Responsible Party (RP) fills out Corrective Action Responsible Party (RP) fills out Corrective Action Consent Agreement Consent Agreement O If RP won t sign Consent Agreement, DEH will issue a If RP won t sign Consent Agreement, DEH will issue a Corrective Action Order Corrective Action Order O Deposit account is funded Deposit account is funded O RP sets up Financial Assurance RP sets up Financial Assurance
Title 22 CCR Section 68400.16 Requires a corrective action process that Requires a corrective action process that fulfills fulfills the following: the following: O Site Site screening using Preliminary screening using Preliminary Endangerment Assessment Assessment (PEA) (PEA) manual manual Endangerment O Adequate Adequate site characterization of release site characterization of release and risk assessment that evaluates assessment that evaluates risk and risk risk O Cleanup Cleanup that is protective of human health that is protective of human health and environment environment (10 (10- -6 risk level) 6 risk level) and
Summary O CAP for past or present CUPA facilities with significant CAP for past or present CUPA facilities with significant releases to the environment releases to the environment O Enforcement, if necessary, Enforcement, if necessary, to ensure corrective action is action is performed performed to ensure corrective O Similar to VAP goals (adequate cleanup to Similar to VAP goals (adequate cleanup to environment and no health risks to future and environment and no health risks to future and present occupants) present occupants)
Case Study - Next Presentation Kyocera America, Inc. Kyocera America, Inc. 11620 Sorrento Valley Road, 11620 Sorrento Valley Road, San San Diego, CA Diego, CA 92121 92121
? ? ? ? ? Questions? Ewan Moffat, EHS Ewan Moffat, EHS- -II, PG, ewan.moffat@sdcounty.ca.gov (858) 505-6856 II, PG, Chg Chg James Clay, CAP Program Facilitator James Clay, CAP Program Facilitator james.clay@sdcounty.ca.gov (858) 505-6969
